Managing a mountain of testimony: Deposition transcript tips for mass tort litigation

When Burns Charest, a nationally recognized plaintiff litigation firm, found itself managing approximately 400 deposition transcripts in the middle of complex opioid litigation, the designation workflow alone became a major operational challenge. Deposition designations in large-scale litigation are not a one-pass process. Each transcript generates rounds of designations, counter-designations, and objections exchanged between the parties — and every round requires precise tracking and efficient editing. At 400 transcripts, that process can bury a litigation team if the right system isn't in place.

Cristina Delise, Of Counsel at Burns Charest, had used Nextpoint during major EpiPen antitrust litigation, where it proved essential for managing designations and coordinating exchanges with opposing counsel. When the opioid matter demanded the same precision at an even larger scale, she brought Nextpoint in again.

With 400 transcripts, the designation process can bury you if you don't have the right tool. Nextpoint is intuitive and allowed the team to easily edit designations, counters, and objections all in one place." ^{Cristina Delise} _{Of Counsel, Burns Charest}

The Burns Charest experience illustrates something true of mass tort deposition management more broadly: the challenge isn't just having a lot of transcripts. Everything about the deposition process — designation rounds, video management, co-counsel coordination, export workflows — multiplies with the volume. The firms that manage it well need a system built for the scale.

Why deposition management is different in mass tort

In standard litigation, a handful of depositions can be managed with a shared folder and a spreadsheet. Mass tort cases routinely involve dozens, hundreds, or in the largest MDLs, thousands of depositions — corporate witnesses, expert witnesses, and plaintiff depositions across multiple jurisdictions, often taken over the span of years.

The MDL structure compounds this. A single set of corporate witness depositions is taken once and made available across all plaintiffs — which means those transcripts become shared infrastructure for the entire litigation, not just one firm's work product. Every firm in the MDL needs to be able to access, search, and work from the same transcripts. And the designation process, which in a bilateral dispute might involve one or two rounds of edits, expands in MDL cases into a multi-party, multi-round workflow with strict court deadlines.

The operational demands that follow — tracking which designations are current, coordinating counter-designations with opposing counsel, preparing video clips for trial, exporting designation reports in formats the court and opposing counsel can use — are not dramatic in isolation. At scale, they become a significant portion of the litigation team's time.

Building a central transcript repository

The foundation of effective deposition management in mass tort is centralization. Transcripts and videos scattered across email threads, Box folders, and individual firm servers create version control problems, collaboration friction, and the constant risk that someone is working from an outdated file.

A centralized repository eliminates those problems by keeping all transcripts, videos, and designation rounds in one searchable platform. When a new firm joins the MDL as a tag-along action, they can access the full transcript library immediately rather than waiting for someone to compile and send files. When a bellwether trial team needs to pull testimony from a corporate witness deposed two years earlier, the transcript is in the same place it has always been, with every round of designations intact.

In the EpiPen matter, Cristina Delise took this a step further: when the court required joint designation filings, she got opposing counsel to submit their designations in a CSV so everything could be uploaded into Nextpoint and tracked in one place.

Every round of designations, counters, and objections was in one place, and it made the project seamless.” ^{Cristina Delise} _{Of Counsel, Burns Charest}

Nextpoint migrated approximately 400 transcripts and videos from the Burns Charest opioid matter into a single centralized platform. Our dedicated services team prioritized the highest-impact materials so the litigation team could begin working immediately.

Managing the designation workflow at scale

The designation process is where mass tort deposition management gets complicated. In standard litigation, designation rounds are manageable — a few back-and-forth exchanges between counsel, tracked informally. In a mass tort MDL with hundreds of transcripts and multiple parties, each transcript may go through several rounds of designations, counter-designations, and objections before the court-ordered deadline. Managing that process without a dedicated system means attorneys spend hours reconciling versions, hunting for the most current draft, and manually preparing designation reports for submission.

A platform like Nextpoint, designed for this workflow, keeps every round of every transcript's designations in one place. Attorneys can track and edit any designation without toggling between systems or navigating competing versions. When opposing counsel submits counter-designations, direct imports add them to the system without requiring manual entry. When the court deadline arrives, your team can generate and export designation reports in the required format without a last-minute scramble.

Searching across transcripts

In mass tort litigation, a deposition transcript is rarely just a record of one witness's testimony. It's also a source of evidence that may be relevant to dozens of individual plaintiff matters, multiple expert reports, and trial preparation across bellwether cases.

That value is only accessible if you can search across transcripts quickly and accurately. A litigation team preparing for a bellwether trial needs to find every instance where a corporate witness addressed a particular product defect, or every expert who testified about a specific causation mechanism, without manually reviewing hundreds of documents.

Transcript searchability also matters for the master repository function discussed in our earlier post on data reuse. When your firm's prior deposition transcripts are searchable alongside current matter materials, a new case doesn't start from zero — it starts from everything you've already established about the key witnesses, the key issues, and the key lines of questioning that worked.

AI transcript summaries: Triaging at volume

When a matter involves hundreds of depositions, getting a working understanding of each transcript quickly is a practical necessity. Attorneys can't read every transcript in full before deciding where to spend deeper review time. In mass tort litigation, that triage decision happens repeatedly as new transcripts come in throughout the course of the matter.

Nextpoint's AI Transcript Summaries generate an immediate working summary of a deposition, identifying key testimony, significant admissions, and the overall arc of the examination. The summaries aren't a replacement for attorney review — they're a tool for deciding where that review is most needed. A litigation team triaging 50 new corporate witness transcripts can use AI summaries to prioritize the three that need immediate attention, rather than spending equal time across all of them before knowing what's there.

In a matter the size of a typical mass tort case, that efficiency compounds significantly over the life of the case.

Video, clips, and trial presentation

Deposition transcripts and video are increasingly inseparable in mass tort trial preparation. Video depositions are standard, and the clips used at trial — whether to impeach a witness, play testimony in lieu of live appearance, or support a demonstrative — require careful management from the moment the deposition is taken.

At scale, the video management workflow involves importing raw deposition videos, syncing them to transcripts, creating clips tied to specific designations, importing clips from opposing counsel, and exporting in multiple formats for use at trial, in mediation, or for submission to the court. In the largest mass tort matters, the clip library for a single bellwether trial can represent months of preparation work.

Nextpoint's Litigation Suite keeps the written and video workflows in the same place, so they stay synchronized rather than drifting apart as the matter develops. Video is synced directly to the transcript — designations made in the text automatically generate corresponding video clips, ready to export for judges, opposing counsel, or trial presentation. Import opposing counsel's designations and the clips come with them. No separate clip management system, no reconciling two sets of files at the end.

Collaboration across firms

Mass tort litigation is almost always a multi-firm endeavor. On the plaintiff side, a Plaintiff Steering Committee coordinates across dozens of participating firms, each with their own cases and counsel. On the defense side, a single defendant may be represented by multiple firms handling different jurisdictions, with local counsel involved in each venue. In both structures, the deposition transcript library is shared infrastructure, and the ability to collaborate on it across firm boundaries matters.

Legacy software creates friction here. Platforms that require installation, complex onboarding, or significant expense to add occasional users lead to collaboration challenges that slow down the mass tort deposition process. Local counsel brought in for a specific jurisdiction shouldn't need a week of training to access the transcripts they need.

Jim Douglass, an analyst at Baker & O'Brien who brought Nextpoint to his firm after using it at Clyde & Co, put it plainly: "The ease of use, once you get people working in it, is so much easier than handing somebody a login to Relativity and saying go find what you need."

Cloud-based access, intuitive interfaces, and pricing that doesn't penalize firms for adding occasional collaborators make it possible to treat the transcript repository as shared infrastructure — not a system that some firms use well and others navigate around.

Ready to take your mass tort deposition workflow to the next level?

Mass tort deposition management is one of the most labor-intensive components of complex litigation, and the process compounds as the number of transcripts grows. The firms that stay ahead of it must have a system built for the scale. Centralized transcripts, streamlined designation workflows, transcript-synced video, and a platform the whole team can actually use: that's what effective deposition management looks like in mass tort. That's what Nextpoint delivers.

Frequently asked questions about mass tort depositions

How do you manage deposition designations in mass tort litigation? Effective designation management in mass tort requires a centralized platform that tracks every round of every transcript's designations in one place — initial designations, counter-designations, and objections — without requiring attorneys to reconcile versions across email or shared drives. The platform should support direct import of opposing counsel's designations and generate court-ready designation reports on demand. At the scale of a typical MDL, managing this process manually or across disconnected systems creates version control problems and consumes significant attorney time that should be spent on strategy.

What is the best way to organize deposition transcripts in an MDL? A central repository housing all transcripts, videos, and designation rounds in a single searchable platform is the foundation of effective MDL transcript management. All firms in the litigation — lead counsel, liaison counsel, participating firms, and local counsel — should be able to access the repository directly rather than receiving files by email. Transcripts should be searchable by keyword, witness, and issue so the library functions as an active resource for case preparation, not just an archive.

How do mass tort firms handle video deposition clips for trial? Video clips in mass tort trial preparation should be managed in the same platform as the written transcripts, synchronized to specific transcript pages and designation ranges. This keeps the written and video records aligned throughout the designation process and ensures that trial clips reflect the final agreed designations rather than an earlier version. The platform should support import of opposing counsel's clips and export in multiple formats for court submission, trial presentation, and mediation.

How many deposition transcripts does a typical mass tort case involve? It varies significantly by matter type and scale, but large pharmaceutical and product liability MDLs routinely involve hundreds of corporate witness and expert depositions, plus plaintiff depositions that can number in the thousands across the full MDL. Burns Charest managed approximately 400 transcripts in a single opioid matter. Some mass tort cases include tens of thousands of plaintiffs, which means significantly larger transcript libraries. The operational demands of transcript and designation management scale directly with volume.

What role does co-counsel collaboration play in mass tort deposition management? In multidistrict litigation, deposition transcripts are shared work product across all participating plaintiff firms. A centralized, cloud-based platform that all firms can access directly — without complex onboarding or per-seat licensing barriers — is essential for treating the transcript library as shared infrastructure rather than one firm's proprietary system. The ability to collaborate on designations in real time, with all parties working from the same version of every transcript, reduces errors, eliminates version control problems, and keeps the designation process on schedule across the full MDL.